regulation (ec) 391/2009 art. 10.1 mutual recognition

Regulation (EC) 391/2009 Art. 10.1 Mutual Recognition

Technical Review Meeting 29 November 2018 in Hamburg

Technical Review Meeting Report

November 2018

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Executive Summary

A full day’s Mutual Recognition Technical Review Meeting (MR TRM) was organized on 29 November 2018 at The Madison Hotel in Hamburg by the EU RO MR Group (MR Group).

The aim of the MR TRM was to:

• present the current status of the MR TR development process Tier 1 to Tier 7 products andenable the collection of feedback on MR technical issues regarding new and existing MR TRsand the MR certification process;

• introduce the status of development of the new Product Evaluation Process (PEP);• talk about suitable (type approved) products for further MR TR development;• discuss with industry participants their respective input and proposals.

The MR TRM was attended by representatives of the European Marine Equipment Industry and other relevant associations along with members of the EU RO MR Technical Committee to enable a two-way exchange of technical information on the development and maintenance of MR TRs.

Overall, the feeling expressed by those attending the MR TRM was, that there were useful and constructive exchange of technical and procedural information related to the MR process under a collaborative atmosphere.

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Contents

Executive Summary .......................................................................................................................... 3

Contents ........................................................................................................................................... 4

Introduction ...................................................................................................................................... 5

EU RO MR Group Presentations ........................................................................................................ 6

Industry Presentations ...................................................................................................................... 6

Overview of TRM Discussions ........................................................................................................... 7

Conclusions ..................................................................................................................................... 12

Action List - Technical Review Meeting, 29 November 2018, Hamburg .......................................... 13

Appendices ..................................................................................................................................... 14

• Appendix A: List of registerd Participants ....................................................................... 14

• Appendix B : MR TRM Agenda ........................................................................................ 15

• Appendix C: EU RO MR Group Presentations .................................................................16

• Appendix D: Industry Presentations ...............................................................................27

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Introduction

This MR TRM was organised by the EU ROs to present the current status of the MR TR development process and to enable the collection and initial discussion including review of feedbacks on MR technical issues regarding new and existing MR TRs and the MR certification process. It was also an opportunity to provide information on the existing MR TRs and related Change Requests and/or Requests for Clarification. Further, the future model to evaluate products for the MR scheme was introduced and explained with the help of an example product as suggested by one of the participating industry representatives.

The MR TRM was attended by representatives of European based Marine Equipment Industry Associations and manufacturers along with members of the EU RO MR Technical Committee. It encouraged a two-way exchange of technical information on the development and maintenance of MR TRs. The list of representation can be found in Appendix A.

The meeting was chaired by the Technical Committee Chair of the EU RO Group (LR), supported by MR Group Secretariat and members of the EU RO MR Technical Committee. Lead AdHoc Group Risk II (ABS) presented the status of development of the revised methodology for safety criticality assessment being under review since 2017.

Details of the agenda of the MR TRM can be found in Appendix B.

The MR TRM objectives were to:

• Present the current status of the MR TR development process and collected feedback ontechnical issues;

• Introduce the development status of the Product Evaluation Process (PEP);• Provide an opportunity for industry input on the development and maintenance process of

Mutual Recognition Technical Requirements (MR TRs) as well as on product consideration.

This report provides an overview of presentations as delivered during the TRM and summarises the discussions and conclusions that were drawn from the MR TRM. It also lists the follow up activities.

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EU RO MR Group Presentations

This paragraph summarizes the content of the presentations given by the EU ROs (Appendix C).

Presentation 1: Update on TC activities

Overview of the agenda and topics in and out of scope for the MR TRM.

- TR Development (Tier 7 industry consultation)- TR Maintenance

Summary of the actions taken during Tier 7 TR development and the industry consultation phase of the Tier 7 MR TR development project with overview of feedbacks received so far.

Summary of TR maintenance process including industry feedback on technical issues relating to TRs that had been collected under use of the MR Group’s maintenance process and procedures.

Presentation 2: Product Evaluation Process (PEP)

Introduction of the Product Evaluation Process (PEP)

Industry Presentations

This paragraph summarizes the presentations given by Industry representatives (Appendix D).

Presentation 1: Danfoss: Variable Speed Drives

Presentation 2: SIEMENS AG: Comparison pilot devices – position switches

Presentation 3: SIEMENS AG: MR TRs vs class rules

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Overview of TRM Discussions

1. Introductions and welcome addresses

Introductions and welcome addresses were given by the Moderator (LR), and the EU RO MR Technical Committee Chair (LR) followed by an introduction round table of the meeting participants.

The Moderator introduced the aim and objectives of the meeting, reminding that all EU ROs are competitors, and emphasizing that no business model related topics, no political discussions, no lobbying and or questions related to IACS involvement are seen as appropriate.

The Moderator reminded that the TRM is a workshop style meeting focussing on the exchange of technical issues, gathering issues of interest from the participants.

After a welcome note by TC Chair, the Moderator addressed the participants emphasizing that the TRM is intended to be the forum for focusing on technical and procedural related aspects of the TR development process to improve the effectiveness of product related technical requirements, but also on the implementation and maintenance process of existing TRs.

An introductory tour de table allowed for an overview over the background of the participants.

Danish Maritime (DM) representative and lead of the Class Group in SEA E acknowledged that the meeting is to discuss technical issues, but that the meeting is also seen as part of the process to lead to a certification regime scheme that is more cost effective and reduces administrative burden.

The MR Group’s Technical Committee Chair introduced the meeting agenda.

The Moderator presented the governance of the MR Group as backbone of the work to comply with Art 10 (1), Reg 391/2009, reiterating that the rules of competing class societies serve as basis for the development of the TRs. As the first contact, Secretariat is the entry point of all inquiries coming from stakeholders.

2. Update on TC activities

TC Chair lead through the technical work of the MR Group, starting with an overview of the status of certificates as a breakdown by region and by product group. TC Chair then presented the TC involvements, outlining the developments since the last TRM and improvements of procedures and resulting documents to ensure consistency in the implementation and maintenance of TR’s, (Request for Clarification [RfC], Change request [CRF], Alert Process, Maintenance Procedure, Product Consideration Process [PCP]).

It was highlighted that the new and improved website now offers a more user- friendly layout and providing comprehensive information on MR processes.

Participants were reminded to subscribe to the website to get alert for news and thus get access to the information provided by the MR Group.

TC Chair presented details and examples of the technical and procedural work in 2018 and gave an outlook on the future work (e.g. finalize Tier 7, TR maintenance with reference to alignment

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proposals, consistency and simplification aspects). She further explained the status of TR development asking industry to further support the development by suggesting products/ products groups to be evaluated using the future Product Evaluation Process (PEP).

It was explained that the revised risk model will be presented to the industry in this meeting for the first time. It was emphasized that this model is still under development based on results and feedback from test cases and one pilot case. The old SRBM is still valid and to be used for the time being. It might be used on base of exceptional cases as a generic model, but it is still subject to adaption to incorporate the lessons learnt and industry comments, once made available in a consultation phase.

It was explained that when deciding how to set up the risk assessment methodology, other standardization entities assessing risks have been inquired and the MR Group made a comparison of existing models to find a way to simplify the approaches to serve the purpose of complying with Art 10(1) of Regulation 391/2009. This led to the first risk model (SRBM). The further development of this model serves the purpose to enable application of more filters to allow a more complex review and to give better technical background on the process and product.

Once the PEP Model is in the stage that it is ready, the MR Group strives for a system through the website, where the experts can directly go through the PEP process, so that it is as transparent and useable as possible.

However, for the time being, the model is under development. A test phase has been arranged to feedback experience with the lessons learnt. The test case product that was presented during the meeting (Variable Speed Drives, VSD) had been tested on the basis of the current status of the new model. The same product was previously not assessed eligible for MR.

On a question related to the referencing of standards, TC Chair explained that the Technical Requirements are based on the most stringent requirement, so whatever standard is used in individual TACs, the MR Group needs to rely on the individual class rules with the highest standard.

Industry was encouraged to raise questions related to the referencing of standards to the MR Group in writing, if further details are required.

TC Chair provided a summary of the TR maintenance process including industry feedback on technical issues relating to TRs that had been collected under use of the MR Group’s maintenance process and procedures.

With regard to the maintenance process of existing TRs it was outlined that the process will need to be brought into the next iteration to accommodate for the comments that have been.

TC Chair presented the principles of maintenance and the maintenance status of MR TR as of Nov 2018 as well as the status of certificates issued for individual product groups. The trend of rising number of certificates issued shows a positive trend.

TC Chair presented considerations regarding the review of existing TRs in a maintenance process, taking into consideration the no. of certificates issued. The content of review is envisaged to include testing requirements, referenced standards, updates of standards, references to other TR’, editorial alignment and limitations and their origin.

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The MR Group shared first ideas on product grouping and the approach.

Industry input during consultation phase

The Moderator stated that there was a relatively low interest from industry with regard to the technical consultation process of Tier 7 product TR development (only 2 comments received on the draft Tier 7 TRs).

SIEMENS corrected the impression that they as a company have provided direct comments. The comments have been provided through IEC Standards Committee and not from SIEMENS.

Product Evaluation Process (PEP)

The Lead AdHoc Group Risk II (ABS), introduced the principles and current status of the Product Evaluation Process (PEP).

The concept was explained, and questions were clarified or taken on board for further consideration. The MR Group explained the intention to publish the PEP on the website to enable manufacturers to make a pre-assessment whether their products can be considered for MR and can subsequently be developed. Guiding questions will support the assessment process. Any type of product can be assessed under PEP.

Two manufacturers raised the question whether in case of an integrated system, an MR certified component can potentially be part of achieving the unit certification. In this context, it was clarified that individual TA certificates cannot correlate with the MR TAC process.

FUA 1: Establish a respective position (MR Group)

A manufacturer shared his experience that there is always the need to have two certificates: TAC together with MR TAC due to non-acceptance of MR TAC by non-EU flag states.

Questions were clarified on the important concept of all ROs that if it comes to system integration, ROs need to always look at the application limitation and whether a product is intended to be integrated into the essential systems.

A manufacturer brought up the question how to go forward with MR TAC to be integrated in systems and what effect such integration does have on the software, i.e. how can software be handled in the MR scheme. This question will be discussed further by the MR Group, e. g. to state software limitations on the certificates, which would require not to change the versioning.

FUA 2: Address how to handle software in the MR scheme (MR Group)

FUA 3: Update the PEP model, and – upon approval - present it to the industry for consideration (industry consultation) (MR Group)

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Presentations by Industry

Danfoss on Variable Speed Drives

Danfoss appreciated that the MR Group has already addressed the proposal for product consideration. 90% of their products are of shelve for which MR certification would be favourable in the market. The respective benefits for Danfoss were highlighted.

Based on previous contacts, their product Variable Speed Drives (VSD) was tested to the new PEP-MR by the TC members of each EU RO with the following results: All reviewers except one found the VSDs to be eligible for MR, however, EU RO‘s Rules limit eligibility for MR when the VSDs are above a certain capacity (kW, kVa) and intended to be installed in an essential services system.

FUA 4: Further work on this test case in cooperation with Danfoss (Technical Committee)

SIEMENS AG: Comparison pilot devices – position switches

SIEMENS elaborated on inconsistencies between the TR Pilot Devices Version 0.1, adoption date 1 July 2018 and the draft TR Position Switches Version 0.0, adoption date 1 January 2019 and proposed possible solutions for alignment. This input was already handed in to the MR Group during the industry consultation phase for the TR development and has been handled by the MR Group. Partly, the proposals have already been taken on board (Position Switches), partly the proposals will be considered in the maintenance cycle (Pilot Devices).

FUA 5: Justification Letter will be sent in reply to the input by IEC Standards Committee during the industry consultation phase of Tier 7, SIEMENS reading in copy (Secretariat)

SIEMENS will be informed about the outcome of the respective maintenance activities

SIEMENS AG: MR TR versus class rules

SIEMENS exemplified that individual class societies only have one document for different kind of devices, where TRs are individual documents covering related fields. There is for example only one class rule document versus 8 MR TRs for low-voltage switchgears.

One EU RO commented that they have one dedicated document for each product in order to provide unambiguous requirements. It has to be taken into account that MR needs to cover several competitors, so there are advantages and disadvantages with the setup.

SIEMENS made a general comment on combining similar products into one TR and suggested that the reduction of different MR TRs to one document would avoid effort and confusion and proposed to establish one MR TR for all low-voltage devices in accordance with the already existing class rules of the individual class societies.

SIEMENS further commented on harmonising technical documentation for similar products and in particular advocated for harmonizing type testing requirements. The comment was supported by the example of EMC criteria's.

SIEMENS observed that in individual class rules tests are independent of the devices and that test descriptions are separate.

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FUA 6: Take the grouping proposal by Siemens into consideration (MR Group)

Any Other Industry Comments

Brunvoll raised the question whether Material is subject to MR. The MR Group replied that Material is not yet addressed. System consists of sub-systems and material. The MR Group reiterated their position.

Brunvoll further observed that TRs seem to be very prescriptive and inquired whether the MR Group has considered to make them function/goal based. It was explained that the most stringent standards have to be used, which is prescriptive.

To Brunvoll it appears that there may be a challenge with regard to transpareny of the PEP Model. The MR Group explained that the TRM 2018 is the first time to publish the the PEP and that the MR Group is grateful for any comments. The MR Group notified the participants that there will be an industry consultation phase on the PEP and offered to clarify any questions also individually, if approached.

Kongsberg commented on the harmonisation of EMC testing requirements with applicable international standards for similar products.

FUA 7: Take the EMC proposal by Kongsberg into consideration (MR Group)

Kongsberg inquired about global acceptance of MR TAC, reiterating that 85% of the world fleet is flying under non-EU flags. Due to the lack of global acceptance, Kongsberg observe insecurity for suppliers. The MR Group explained that MR is subject to flag state sovereignty in non-EU flag states (Recital 25) and that this question could be raised to DG MOVE.Reference was made to the factual report summarizng the arguments given at the EU RO MRWorkshop, 5th September 2018, which can be found on www.euromr.org.In this context it was also mentioned that in 2009, reduction of trade barriers was one of the aims ofArt 10(1), but that no impact analyses have been exercised.

Kongsberg further asked the MR Group to counteract arguments that doubt the quality of MR TACs, as they should have the same quality, globally. It was clarified that TRs respect the most rigourous standards. They suggested that this could be better displayed on the MR TAC with a respective remark on the certificate.

FUA 8: Revisit the minimum contents on the MR TAC (MR Group)

The representative of the Society of Maritime Industries/UK inquired whether the MR Group has benchmarked the timing of the MR process. It was explained that the MR TR process follows a strict milestone process. Regarding the turnaround time for certification, it was mentioned that individual class societies do have respective KPIs .

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Conclusions

The MR TRM 2018 covered a wide range of issues related to

- the status of the product evaluation process (PEP Model)- the MR TR development process- the MR TR maintenance process- the processes to maintain certification integrity under MR

and how to handle specific topics as raised by industry representatives.

The MR Group thanked all participants for their engagement, the valuable contributions and the fruitful discussions. It was concluded that the TRM fulfilled the aim to inform about the latest status and to share ideas and proposals to enhance the processes.

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Action List - Technical Review Meeting, 29 November 2018, Hamburg

Actions for EU RO Group:

No. Issues Raised 1. Establish a respective position (MR Group)

2. Address how to handle software in the MR scheme (MR Group)

3. Update the PEP model, and – upon approval - present it to the industry for consideration (industry consultation) (MR Group)

4. Further work on this test case in cooperation with Danfoss (Technical Committee)

5. Justification Letter will be sent in reply to the input by IEC Standards Committee during the industry consultation phase of Tier 7, SIEMENS reading in copy (Secretariat)

6. Take the grouping proposal by Siemens into consideration (MR Group)

7. Take the EMC proposal by Kongsberg into consideration (MR Group)

8. Revisit the minimum contents on the MR TAC (MR Group)

Actions for Industry Associations:

No. Issues Raised

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Appendices

Appendix A: List of TRM Participants

Participants

EU RO MR Group

EU RO MR TC CHAIR (LR)

EU RO MR Secretary

EU RO MR Secretariat

ABS SC Member BV TC Member CCS SC Member CRS TC Member DNV GL TC Member IRS TC Member KR TC Member LR SC Member NKK TC Member PRS TC Member RINA TC Member RS TC Member

Industry Brunvoll AS Danish Maritime (DM)Eaton VSM Schneider Electic Kongsberg Maritime ASA Federation of Norwegian Industries Rolls Royce Marine AS SEA Europe Siemens AG Danfoss Drives A/S Danfoss Drives A/S Society of Maritime Industries/UK Netherlands Maritime Technology

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Appendix B: MR TRM Agenda

Meeting Type: 4th Industry Technical Review Meeting Location: Hamburg, The Madison Hotel Date: Thursday, 29 November 2018 Start Time: 10h00 (local time)

AGENDA

Time Item Presenters 10:00 1. Introductions and welcome address from:

a. EU RO MR Group;b. Relevant industry participants;

Moderator (LR) TC Chair (LR) Relevant industry participants

10:30 2. Product Evaluation Process (PEP) Lead AdHoc Group Risk2 (ABS)

12:00 Lunch 13:00 3. Update on TC activities:

a. TR Development(Tier 7 industry consultation)

b. TR Maintenance

TC Chair (LR)

14:00 4. Feedback by industrya. Maintenanceb. Development

Relevant industry participants

15:00-15:30 5. Summary of discussions, review of actionsand meeting close

TC Chair (LR)

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EU RO MR Group

Technical Review Meeting 2018

Hamburg, 29 November 2018

Timetable based on Agenda

Agenda

Time Item Presenters

10:00 1. Introductions and welcome address from principlesand scope of TRM

Moderator (LR)TC Chair (LR)Relevant industry participants

10:30 2. Update on TC activitiesa. TR Development (Tier 7 industry consultation)b. TR Maintenance

3. Safety Criticality Product Evaluation Process (PEP)

TC Chair (LR)

Lead AHG Risk2 (ABS)

12:00 Lunch

13:00 4. Feedback by industrya. Maintenanceb. Development

Relevant industry participants

14:45 –15:30

5. Summary of discussions, review of actions and meeting close

TC Chair (LR)

Appendix C: EU RO MR Group Presentations

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Introduction and Principles of the EU RO MR Group

• Decisions and guidance within

EU RO MR Program, overall

responsible and ensuring

compliance

• TRM Meeting are an integrated part of

the MR group activities with solely

focusing on technical and related

procedural TR Development

processes

SecretariatSince 2013

Steering Committee Technical Committee

Stakeholders

Task Group

Agenda item 1– Introduction and Principles EU RO MR Group

Status of Mutual Recognised TA Certificates

• Through development and

application of transparent

procedures and processes, 138 MR

Type Approval Certificates have

been issued

(as of November 2018)

• This has seen global coverage

Some statistics as per November 2018

Agenda item 1– EU RO MR Group

68%

24%

8%

% of MR TACs by Region

Europe

Asia

North America

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Status of Mutual Recognised TA Certificates

1 5

Status November 2018 - % of MR TACs Issued by Product

Agenda item 1– EU RO MR Group

• Development/ improvement of procedures and resulting documents to

ensure consistency in the implementation and maintenance of TR’s,

(Request for Clarification [RfC], Change request [CRF], Alert Process,

Maintenance Procedure, Product Consideration Process [PCP])

• Renewal and improvement of the new web site aiming to a more user

friendly layout and providing comprehensive information on MR

processes

• Participation in the Task Group to consider feedback by stakeholders to

current criticality assessment methodology

TC involvements since last TRM

Agenda item 2– Update on TC activities

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Technical related activities

• TR and TI for Plastic Piping System” finalized and approved

• TR for “Sensors” finalized and approved

• TI for definition of fishing vessels finalized for TR Sensors finalized

• Clarification of application limitation for TR Electric/ Electronic Relay

finalized

• Alignment of TR’s in regards to reference standard for test requirements

finalized

• Analysis of Industry feedback

Procedural related activities

• Task Group Referencing of Standards

• Several workshops conducted to review and revise former ERM

• Results of workshop presented to AdHoc Risk Group II for further

elaboration and implementation

• Test cases prepared and discussed to verify functionality of PEP, e.g.

pilot “ variable speed drives”

YTD Activities


• TR Maintenance in regards to alignment proposals, consistency and

simplification aspects

• TR Development (Industry to support further TR development to allocate

further products/ products groups to be evaluated using PEP)

• Feedback to SC for process adjustment needs

Agenda item 4 – Feedback from TC

Ongoing Activities


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Status of new proposed MR TR Development products in 2018

• Anti Chafing Chain : not eligible

• Pilot: Variable Speed Drives: not eligible

• Insulation Monitoring / Insulation Fault Detectors: ready for development

Impact:

Revision to TR Development cycle:

Starting January 2019 the MR group decided to initiate maintenance work

on the 62 existing TRs and to further continue the TRs development

process based on itemized approach in order to be more time flexible for

new products

• Finalize Tier 7


Future Activities

TR Development

Feedback from Industry


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IEC Standards Committee

TR Development



Industry feedback in regards to Tier 7 development are related to:

• application limitations in regards to voltage ranges

according applicable IEC standard

• type testing requirements in regards to EMC criteria's if

applicable

• general comment on combining similar products into one TR

• general comment on harmonising technical documentation

for similar products

TR Development



Based on limited number of comments received by Industry (1 TR only), it is

concluded that TR’s are found satisfactory for the concerned products and

can be further used by the industry.

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2 independent maintenance trigger for yearly maintenance

• Periodical review:

Update on Rule development and impact to existing TR’s

Review of CRF and conclusions and impact analysis to existing TR’s

• Annual Review

Review of TI and impact analysis to existing TR’s

TR Maintenance


Status of Mutual Recognised TR November 2018

Version 0.017

Version 0.19

Version 0.213

Version 0.316

Version 0.44

Version 0.51

Version 0.62

• TR’s been frequently reviewed andrevised were appropriate

• Process of revision currently underconsideration to improve efficiency ofgroup activities and faster response toIndustry changes

• More than 700 reviews have beenconducted on all existing TR‘s

Version 0.027%

Version 0.115%

Version 0.221%

Version 0.326%

Version 0.46%

Version 0.52% Version 0.6

3%


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0

1

2

3

4

5

6

7

8

9

10

20142015

20162017

2018

Applied TR's 2014 - 2018

(Low Voltage) Switches Adjustable Steel Chock Air Pipe Automatic Closing DevicesCable Trays and Ducts Cable Trays and Ducts (Metallic) Circuit BreakersClass III Pipes Fittings (Dy <= 500 mm) Computers and Programmable Logic Controllers ContactorsDisplay monitors, video screens & terminals Electric Cables - Heating Cables Electrical / Electronic RelaysElectrical Actuator for Valves LV Enclosures & Boxes Plastic Piping Systems (Components)Pressure Gauges / Transmitters Pressure Gauges/Transmitters Resin ChocksSensors Solenoid Valve Assembly SwitchesTemperature Gauges & Transmitters


TR Maintenance


TR Maintenance

(Low Voltage) SwitchesAdjustable Steel Chock

Air Pipe Automatic Closing…Cable Trays and DuctsCable Trays and Ducts…

Circuit BreakersClass III Pipes Fittings (Dy…

Computers and…Contactors

Display monitors, video…Electric Cables - Heating…

Electrical / Electronic RelaysElectrical Actuator for Valves

LV Enclosures & BoxesMonitors, Terminals

Plastic Piping Systems…Pressure Gauges /…

Pressure…Resin Chocks

SensorsSolenoid Valve Assembly

SwitchesTemperature Gauges &…

Breakdown of TR Application by StakeholdersMost applied TR‘s are:

1. Computers and Programmable Logic Controllers2. Sensors3. Display monitors, video screens & terminals4. Plastic Piping Systems (Components)5. Electric Cables - Heating Cables6. Temperature Gauges & Transmitters7. Air Pipe Automatic Closing Devices and Cable Trays

and Ducts (Metallic)8. Switches9. Circuit Breakers, Contactors, Electrical / Electronic

Relays, LV Enclosures & Boxes, Pressure Gauges /Transmittersand Resin Chocks

10. Adjustable Steel Chock, Cable Trays and Ducts ,Class III Pipes Fittings, Electrical Actuator for Valves,Pressure Gauges/ Transmitters, Solenoid ValveAssembly

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TR Maintenance

TR maintenance Proposal (under consideration)

• review the existing scope. Start with 12 TR’s from similar product groups and finalize yearly 12 TR’s

a) Content of review:

• testing requirements• referenced standards• updates of standards• references to other TR’s• editorial alignment• limitations and their origin


TR Maintenance


b) Approach:

• Compile similar products from their product description and applicable productstandards for all exiting TR’s to select 12 TR’s

• Mapping of design requirements• Mapping of test requirements• Elaborate references to other TR’s• Elaborate limitations• Agree text modules for product description, design, testing, limitations

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TR Maintenance


Possible product groups

Electronic equipment ( Computers, PLC, Monitors Touch Screens, Electronic Relays, Actuator..)Measuring equipment ( Gauges, Sensors…)Electrical power equipment ( Switches, CB, Contactors, Battery Charger ….)Control elements ( Pilot devices, Sensors, Contactors, ActuatorValvesPiping SystemsCables

Product Evalutation Process Development Steps

Agenda item 3 – Product Evaluation Process

Product Evaluation Process – PEP-MR

Developments:

• Existing Methodology for Safety Criticality Assessment under review

since 2017

• PEP-MR methodology developed to follow requests from

stakeholders to focus more on technical aspects of eligibility

assessment: April – October 2018

• Initial Group approval granted Oct 2018, including following

documents:

• PEP-MR

• Revised Definitions as applicable to the model

• Transmitted to TC for evaluation & testing with product test cases

• PEP-MR introduced to industry representatives during the TRM

meeting

• Guiding Questions / Instructions under development to assist with

the implementation and future application the process

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Product Evaluation Process

Agenda item 3 – Product Evaluation Process

Product Evaluation Process – PEP-MR

Improvements over Simplified Risk Based Model (SRBM)

• Moved away from Opt-In, Opt-Out Question Format

• Changed from generic questions to more technically focused criteria

based on Class Rules and regulatory requirements, as applicable

• Assessment Process consisting of 3 Levels of Evaluation

• Basic Evaluation focusing on applicable Standards &

Regulations

• Product Evaluation focusing on type of product and Rule

Requirements for Design Assessment / Survey

• System Evaluation focusing on integration and application case

of product in Ship‘s System

• Can be applied by any EU RO in conjunction with their Rules

• Transparent Evaluation Process – to be publically available and usableby industry and manufacturers to test eligibility of their products

Thank you!

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2 | DDS-P / Danfoss DrivesHard copy or electronic copy may not be disclosed to a third party

EU RO MR Technical Review Meeting Oct, 29th 2018

We take no responsibility for the information, used the SPS / IPC databaseWe take no responsibility for the information, used the SPS / IPC database

Appendix D: Industry Presentations

EU RO MR Group Technical Review Meeting 2018


DANFOSS Presentation

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Variable Speed Drives (VSD) in general

Basic functionalities: Controls electric motors depending on application Can change speed and torque on the motor

Advantages: Save energy and improve efficiency of systems Matches speed, torque or power of a drive/motor to the application Reduce mechanical stress on machines Lower noise levels and improved working environment


Danfoss VSD Type Approvals

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Danfoss VSD in Marine applications

Taken from catalogue page 22.


Danfoss VSD in Marine applications

Taken from catalogue page 23.

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Advantages of VSD in EU RO MR

Simple and less time consuming certification, benefitting Danfoss,customers and certification societies.

Clear requirements for product design making it easier to scope,design and develop new products.

One set of Marine requirements reduce cost of development andthereby selling price on our products, lowering price on marineprojects in general.

Shipbuilders can easily use the same product for ships sailingunder a flag from EU.

LV Soft starters are already in scope today (Tier 5, no. 51), andVSD resembles them.

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EU RO Technical Review MeetingComparison pilot devices –position switches

siemens.comSiemens AG 2018



Siemens AG DF CPComparison pilot devices – position switches

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© Siemens AG 2013. All Rights Reserved.

29.11.2018 Michael Schroeck / DF CP R&D VC 2Page 3

EU RO Technical Review Meeting: Tier 5

• References 3

• Application limits 4

• Technical requirements 5

• EMC 6

• Technical Documents 7

• Summary 8



EU RO Technical Review Meeting: Pilot devices – Position switchesReferences

Extracts are taken from:

TR Pilot Devices Version 0.1, Adoption date 1 July 2018

Draft TR Position Switches Version 0.0, Adaption date 1 January 2019

IEC 60947-5-1, Edition 4.0, 2016-05

Extracts are taken from the newest version

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EU RO Technical Review Meeting: Pilot devices – Position switchesApplication limitations: here voltages

Pilot Devices

Position Switches

IEC 60947-5-1

Correct TR Position switches to 600V d.c.



EU RO Technical Review Meeting: Pilot devices – Position switchesTechnical Requirements

Pilot Devices

Position Switches

Allign especially in respect to environmental categories

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EU RO Technical Review Meeting: Pilot devices – Position switchesEMC Requirements

Pilot Devices

Position Switches EMC Requirements according IEC 60947-5-1 and IEC 60947-5-2 are missing

Replace IEC 60947-4-1 with IEC 60947-5-1 for pilot devices

Include EMC requirements for position switches



EU RO Technical Review Meeting: Pilot devices – Position switchesTechnical documents to be submitted

Pilot Devices

Position Switches

Allign technical documents

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EU RO Technical Review Meeting: Pilot devices – Position switchesSummary

Pilot Devices and Position Switches are covered in one IEC –standard (IEC 60947-5-1)

Different requirements/ratings, etc. are identical (voltages, contact-ratings,enclosure ratings, etc.)

Make one TR for both products to avoid differences



EU RO Technical Review Meeting: Tier 5

Michael SchroeckCertificationDigital Factory DivisionControl ProductsDF CP R&D VC 2

Werner-von-Siemens-Str. 4892224 Amberg, Germany

Phone: +49 9621 80 2417

E-mail:[email protected]

siemens.com

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MR TR versus class rulesSiemens AG DF CP

siemens.de/sirius© Siemens AG 2017



Siemens AG DF CPMR TR versus class rules

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© Siemens AG 2016

28.11.2018Seite 3 siemens.de/sirius

MR TR versus class rulesContent

• Overview MR TR and class rules 3

• Disadvantage of current approach 6

• Aim 7

• Location/Environmental Classes/Categories 8

© Siemens AG 2016


MR TR versus class rulesOverview of MR Technical Requirements and class rules

Class rules (one document)

BV: AutomationABS: electrical equipmentCCS: electrical installationsDNV GL: electrical, electronic and programmable equipment and systemsLR: Electrical Equipment, Control and Monitoring Equipment, Instrumentation

and Internal Communication Equipment, Programmable Electronic SystemsMRS: Electrical equipmentNK: Control and Instrumentation equipment and electrical installationsRINA: Automation

Only one document for different kind of devices

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© Siemens AG 2016



Example

DNV GL: electrical, electronic and programmable equipment and systems

Tests are independent of the devices

© Siemens AG 2016



class rules (one document)

one class rule document versus 8 MR TRs for low-voltage switchgear

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© Siemens AG 2016


MR TR versus class rulesDisadvantage of different MR TRs

Disadvantage of different MR TRs

• Effort to maintain the regulations is higher• Formal differences (no technical need) will appear• Surveyor has to be familiar with different TRs

The reduction of different MR TRs to one document will avoid effort and confusion

© Siemens AG 2016


MR TR versus class rulesAim

Only one MR TS for all low-voltage devicesaccording the already existing class rules of the individual class societies

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© Siemens AG 2016


MR TR versus class rulesLocation/Environmental Classes/Categories

Extract from DNVGL-CG-0339: Extract from LR Test Specification Number 1:

© Siemens AG 2016


MR TR versus class rulesLocation/Environmental Classes/Categories

Extract from RINA Rules Part C: Extract from EU RO MR TR-Draft Position Switches:

Requirements could be also in the Technical requirements/Rules itself Check all the Technical requirements, like for pilot devices

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© Siemens AG 2016


MR Technical requirements versus RO rulesContact

Michael SchroeckCertificationSiemens AG - DF CP R&D VC 2

Werner von Siemens Str. 4892224 Amberg

Tel.: +49 9621 80 2417

E-Mail: [email protected]

www.siemens.de/sirius

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